Please Read then Act: PRA Redefined

A site any compliance or operations professional should be monitoring regularly is the Paperwork Reduction Act (PRA) listing. This page is a gold mine if you are looking to shape what you need to implement later. If I could change PRA to stand for something else to illustrate the importance, it would be Please Read, then Act!

Typically, this is where the Centers for Medicare & Medicaid Services (CMS) posts proposed changes and requests for information or comment. For example, when the agency proposes to change Part D reporting technical specifications, the changes and supporting statements are posted on this site. This gives the public (you!) the opportunity to review and provide comment within a comment period. And it is not just Part D; you will find documents related to other programs such as Fee For Service Medicare, PACE, Exchange and Medicaid.

Let’s walk through an example. CMS posted their proposed changes and supporting statement for the Notice of Denial of Medical Coverage (or Payment) (NDMCP – those pesky denials). Upon review of the proposed changes, I identified two areas of opportunity. In one instance, there is room to further clarify language directed at a beneficiary filing an appeal, and in the other instance, there is opportunity to clarify the instructions to the plan. To submit comments electronically, I went to regulations.gov and found the document in question, hit the “Comment Now!” button and voilà – submitted.

Implementation is not simple. Do not get caught in a situation where you struggle with something confusing, arguably unreasonable, or impossible to complete. Take the opportunity to review this site often, or subscribe to the RSS feed to be notified more quickly. You may often find something the agency missed, or you may provide an improved solution that reduces burden on you, your organization, and your beneficiaries.